DEFCON COMPANY POLICY FOR CORPORATE GOVERNANCE, COMPLIANCE, AND STEWARDSHIP

Our Commitment to Corporate Governance

Defense Contract Support Company (DEFCON Support) is proud of our impeccable reputation.

The company owner, Hameed Mohammed, is well-known, and highly respected throughout the business community of Kuwait for his forthrightness and business acumen. Under his guidance and at his direction, we are committed to conducting operations with the highest standards of business conduct and ethics. We believe that a strong and proactive culture of ethics is critical to the company's future success and continuing growth. For ethics and integrity to be the foundation of our culture, all of us, every employee, must be committed. Performing with integrity is every employee's responsibility and there is no room for compromise. Our values apply to everyone in the company. The following is a summary of our Code of Business Conduct and Ethics.

All our employees are given a copy of and briefed on our Code of Business Conduct and Ethics when they become a part of the team, and annually as a refresher. The Code identifies for us, as a company, and for all those with whom we do business, the values and principles that guide our business relationships. We are committed to the principles of honesty, integrity, and fairness in everything we do. Our code of ethics applies to all officers, managers, employees, and representatives of DEFCON Support. Ethical decision-making depends on the transparent understanding and commitment to Company values and principles combined with good personal judgment. We expect you to give a good impression of the company, to be faithful to its values, and to conduct yourself in a manner that brings credit to you and the company.

Respect for People and Nondiscrimination

We are committed to providing a work environment that is free from discrimination or harassment of any type. We will not tolerate the use of discriminatory slurs; unwelcome, unsolicited sexual advances or harassment; or any other remarks, jokes or conduct that creates or fosters an offensive or hostile work environment. Employees at all levels of the organization must act with respect and civility toward coworkers, customers and others.

We don’t tolerate discrimination based on race, religion, gender, age, marital status, national origin, sexual orientation, citizenship status, or disability. We prohibit discrimination in decisions concerning recruitment, hiring, compensation, benefits, training, termination, promotions, or any other condition of employment or career development.

Legal Compliance

DEFCON Support is committed to obeying all laws and regulations applicable to doing business. Violation of domestic or foreign laws, rules and regulations may subject an individual, as well as our company, to civil and/or criminal penalties. You should be aware that conduct and records, including emails, are subject to internal and external audits, and to discovery by third parties in the event of a government investigation or civil litigation. It is in everyone's best interests to know and comply with our legal and ethical obligations. If any employee has any questions regarding compliance with laws or regulations, contact either the General Manager, or the Company Owner/Operations Manager.

Financial Records

Be careful, accurate, and complete when making or reporting financial entries or transactions. Disclose problems and discrepancies promptly. Never falsify or alter financial records. Do not sign documents if you do not have proper authority. And never make or approve payments on behalf of the company if they will be used or might be used for something other than the stated approved business purpose. All employees are responsible for insuring that travel, material, and other expenses are recorded truthfully and correctly.

Environmental and Workplace Safety

We must comply with all applicable environmental laws. DEFCON Support is committed to conducting business in an environmentally responsible manner that minimizes any environmental impact. All employees must take appropriate actions in using, generating, handling and disposing hazardous materials and report all concerns to their supervisor or other appropriate person. Additionally, all employees must speak up when health, safety or security issues arise. Be attentive to hazard prevention and report accidents and injuries promptly to your supervisor or contact a member of the Executive Management Team. We expect everyone to honor and keep our commitment to maintain a drug- and alcohol-free work environment.

Commitment to Quality

At our company, we strive to do the job right, on time and always to the contractual expectations of the customer. While striving to get it right, we must also report any discrepancy, deviation, mistake or failure, with regard for the highest ethical standards and personal integrity. Our employees are taught to never falsify documents or conceal operational or component problems; always receive proper approvals before deviating from any requirement; never substitute equivalent materials; never utilize lower quality or unapproved materials; and always conduct all tests and inspections as required.

International

We must comply with the applicable laws in all countries in which we travel, operate and otherwise do business, including laws prohibiting bribery, corruption or the conduct of business with specified individuals, companies or countries. The fact that in some countries certain laws are not enforced or that violation of those laws is not subject to public criticism will not be accepted as an excuse for noncompliance. In addition, we expect employees to comply with U.S. laws, rules and regulations governing the conduct of business by its citizens and corporations outside the U.S.

These U.S. laws, rules and regulations, which may extend to all our activities, include the foreign corrupt practices Act (FCPA), International Trafficking in Arms Regulations (ITAR) and other export control laws. Attention to potential violations related to technical data resident on computers and laptops or in presentations and technical support documentation is vital. If any of our employees have a question as to whether an activity is restricted or prohibited, seek assistance from your superior or a member of Executive Management committee before taking any action.

Conflicts of Interest

A conflict of interest occurs when an individual's personal interest may interfere in any way with the performance of his or her duties or the best interests of the company. Employees must be free from influences that conflict with the best interests of the company or might deprive the company of their undivided loyalty in business dealings. Even the appearance of a conflict of interest where none actually exists can be damaging and should be avoided.

The following are examples of situations that may, depending on the facts and circumstances, involve conflicts of interests:

• Being employed by (including consulting for) a competitor, customer or supplier;
• Owning, directly or indirectly, a significant financial interest in any entity that does business, seeks to do business or competes with us;
• Soliciting or accepting gifts, favors or preferential treatment;
• Moonlighting without permission;
• Exercising supervisory authority over a co-worker who is also a family member.

If an employee has any question about a potential conflict or if they become aware of an actual or potential conflict, they should discuss the matter with the company legal department.

There are specific government restrictions on hiring former government personnel. Any contacts relating to employment must be coordinated with the Human Resources Manager. Employees may not have direct employment conversation with any government personnel.

Timekeeping

Our employees are taught to accurately and honestly record time spent each day on each job on which they work. We understand that this record is vitally important. In addition to recording attendance and hours worked for computing pay, time records are the basis for billing our customers. Falsifying time records is fraudulent, and may be looked upon as a criminal offence. All employees are responsible for the accuracy of their individual time records. They understand that in signing their timecard, they are certifying that it is true and accurate.

Competitive Sensitive Data

No DefCon Support employee, consultant, or representative may solicit, obtain, or utilize source selection information relating to government procurement. In addition to materials so marked by the government, source selection information includes bid prices submitted in response to a solicitation; source selection plans; technical evaluation plans; technical evaluation of competing proposals; cost or price evaluation of competing proposals; competitive range determination; ranking of competitors; reports and evaluation of source selection boards; and government agency planning, programming, and budgeting system information.

Similarly, no DefCon Support employee, consultant, or representative may solicit, receive, or utilize any other company's proprietary material other than as authorized specifically by the company.

Gifts and Entertainment

Business entertainment and gifts are meant to create good will and sound working relationships and not to gain improper advantage with customers or facilitate approvals from government officials.

Unless express permission is requested and received, entertainment and gifts cannot be offered, provided or accepted by any employee unless consistent with customary business practice, as per company policy, and not of greater than nominal or token value. Our customers, suppliers and the public at large should know that the judgment of our employees is not for sale. Employees with procurement responsibility can never accept anything of any value from a vendor or supplier.

Protection and Proper Use of Company Assets

Effective use of company resources is critical to our bottom line, and the resources should be used principally for business purposes that advance the company's strategic objectives. Occasionally, however, limited personal use is permitted when it does not compromise company interests. Our employees are encouraged to use these resources wisely, demonstrate efficiency, and guard against waste. They are instructed to limit time spent on personal affairs to a reasonable duration and frequency – always incidental to their workday and never charged to the company or customer. Personal use must not interfere with or adversely affect job performance or the job performance of any other person or organizational requirements. Employees may never use company assets in a disruptive or offensive manner to others (e.g., involving sexually explicit materials that are discriminatory, hateful or threatening).

Employees should be mindful of the fact that DefCon Support retains the right to access, review, monitor and disclose any information transmitted, received or stored using company electronic equipment, with or without an employee's or third party's knowledge, consent or approval and in accordance with applicable law, and employees should have no expectation of privacy in connection with this equipment.

Proprietary Data

One of DefCon Support's most important assets is its information. Employees who have received or have access to proprietary information should take care to keep this information company private. Because we interact with other companies and organizations, we may be aware of competition-sensitive data from customers before that information has been made available to the public. All employees must treat this information in the same manner as they are required to treat DefCon Support proprietary information. There may even be times when employees must treat as private the fact that we have an interest in, or are involved with, another company. We cannot, and will not, accept unauthorized competitive proprietary data.

Resources

All employees are encouraged to seek guidance or information from their supervisors or our Human Resources Department whenever they have a question or concern. Our HR Manager is available to answer any question you may have.

Our Commitment

If any employee becomes are aware of a suspected or actual violation of our code of standards by others, they have a responsibility to report it. Whether they choose to speak with their supervisor or others, they can do so without fear of any form of retaliation. We will take prompt disciplinary action against any employee who retaliates against another, up to and including termination of employment.